Frank v. Commissioner
United States Tax Court
Held, the petitioners, who had no business and no permanent home, are not entitled to deduct traveling expenses and legal fees incurred during the taxable year on a trip to investigate numerous business properties with the purpose in mind of finding a suitable enterprise to purchase and operate.
1Opinion of the Court
OPINION.
Van Fossan, Judge:
The only question presented is whether the petitioners may deduct $5,965 in the determination of their net income for the year 1946 as ordinary and necessary business expenses or as losses. The petitioners base their claim for deductions upon section 23 (a) (1) and (2) and (e) (2) of the Internal Revenue Code.1 The evidence reasonably establishes that the petitioners expended the amount of expenses stated in our Findings of Fact during the taxable year in traveling, telephone, telegraph, and legal expenses in the search for and investigation of newspaper and radio…
2Cases cited4 opinions
- McDonald v. CommissionerSupreme Court of the United States · 1944
- Beck v. CommissionerUnited States Tax Court · 1950
- Tyler v. CommissionerUnited States Tax Court · 1946
- Parker v. CommissionerUnited States Tax Court · 1943
3Cited by148 opinions
- Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
- Polachek v. CommissionerUnited States Tax Court · 1954
- Walet v. CommissionerUnited States Tax Court · 1958
- Koons v. CommissionerUnited States Tax Court · 1961
- Owen v. CommissionerUnited States Tax Court · 1954
143 more not listed; retrieve them via the Exa API.